XI. INTIMATE'S GROSS PROFIT ANALYSIS IS ON A SPECIFIC PUBLISHER'S PRODUCT LINE BASIS (COMPARING DEFENDANTS' EFFECTIVE DISCOUNTSWITH INTIMATE'S DISCOUNT), AND NOT A COMPARISON OF PROFIT MARGINS, 30
XII. INTIMATE HAS PROVIDED SUBSTANTIAL EVIDENCE THAT DEFENDANTS INDUCED AND/OR KNOWINGLY RECEIVED THE UNLAWFUL DISCOUNTS, 30
XIII. INTIMATE HAS SHOWN THAT DEFENDANTS KNEW OR SHOULD HAVE KNOWN THAT THE PRICES THEY RECEIVED WERE DISCRIMINATORY AND UNLAWFUL, 31
XIV. EXPERT TESTIMONY IS NOT REQUIRED; AND INTIMATE HAS VARIOUS EXPERTS TO PROVE LIABILITY AND DAMAGES, 34
XV. INTIMATE SUFFERED ACTUAL INJURY CAUSED BY THE DISCRIMINATION; AND THERE IS NO FLAWED DAMAGE MODEL, 35
XVI. INTIMATE HAS PROVIDED PROOF OF ACTUAL DAMAGES, 37
XVII. INTIMATE'S LOSSES WERE CAUSED BY DEFENDANTS, 38
XVIII. INTIMATE HAS PROVED IT IS ENTITLED TO INJUNCTIVE RELIEF, 38
XIX. INTIMATE IS NOT OUT OF THE BOOKSELLING BUSINESS; IT IS UNABLE TO COMPETE WITHOUT OBTAINING DEFENDANTS' DISCRIMINATORY PRICES, 40
XX. INTIMATE HAS CURRENT EVIDENCE ABOUT DEFENDANTS' ACTIVITIES, 40